18 SAUNDERS v. UNITED KINGDOM JUDGMENT concerned. Furthermore, it had to be remembered that the kind of person questioned by the inspectors was likely to be a sophisticated businessman with access to expert legal advice, who had moreover chosen to take advantage of the benefits afforded by limited liability and separate corporate personality. c) The Commission 65. The Commission considered that the privilege against self-incrimination formed an important element in safeguarding individuals from oppression and coercion, was linked to the principle of the presumption of innocence and should apply equally to all types of accused, including those alleged to have committed complex corporate frauds. In the instant case, the incriminating material, which the applicant was compelled to provide, furnished a not insignificant part of the evidence against him at the trial, since it contained admissions which must have exerted additional pressure on him to take the witness stand. The use of this evidence was therefore oppressive and substantially impaired Mr Saunders’s ability to defend himself against the criminal charges he faced, thereby depriving him of a fair trial. At the hearing before the Court, the Delegate stressed that even steadfast denials of guilt in answer to incriminating questions can be highly incriminating and very damaging to a defendant. This was so in the present case as the answers were used against him both in the opening and closing speeches and in cross-examination to establish that the answers given to the inspectors could not be believed and that the applicant was dishonest. d) Amicus curiae 66. Liberty, with reference to various international human rights treaties and the law existing in a number of Contracting Parties, requested the Court to find that Article 6 (art. 6) prevents self-incriminating evidence from being obtained from an individual under threat of judicial sanction and from being admissible in criminal proceedings. 2. The Court’s assessment 67. The Court first observes that the applicant’s complaint is confined to the use of the statements obtained by the DTI inspectors during the criminal proceedings against him. While an administrative investigation is capable of involving the determination of a "criminal charge" in the light of the Court’s case-law concerning the autonomous meaning of this concept, it has not been suggested in the pleadings before the Court that Article 6 para. 1 (art. 6-1) was applicable to the proceedings conducted by the inspectors or that these proceedings themselves involved the determination of a criminal charge within the meaning of that provision (art. 6-1) (see, inter alia, the